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IRS Guidance Declares That Taxpayers Must Include Staking Rewards in Gross Income

On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which concludes that the fair market value of staking rewards received by a cash-method taxpayer is includible in the taxpayer’s gross...more

IRS Releases Memorandum on the Tax Consequences of a Blockchain Protocol Upgrade

On April 21, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice memorandum (ILM 202316008), concluding that a protocol upgrade to the consensus mechanism of a cryptocurrency blockchain that did not...more

IRS Releases Notice on the Taxation of NFTs as Collectibles

In its first published guidance addressing non-fungible tokens (NFTs), the Internal Revenue Service (IRS) released Notice 2023-27 on March 21, 2023, announcing its intent to issue guidance related to the taxation of certain...more

IRS Releases Memorandum on Deducting Cryptocurrency Losses

On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more

Final and Proposed BEAT Regulations Provide Some Relief

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

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